Topics covered in this paper include:
- what is a Phillips type service trust?
- what the Commissioner said about Phillips type service arrangements prior to the draft ruling
- how does the draft ruling and guidance document impact upon Phillips type service trusts?
- what the guidance document says about the key characteristics of an allowable service trust?
- what characteristics should be avoided in a service trust?
- are there any safe harbours?
- is it necessary to undertake transfer pricing review to determine service fees?
- how important is documentation?
- retrospective impact of the draft ruling
- planning approach - what needs to be done NOW!